“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT

37 ITR 288 · 1959 · Supreme Court

570

citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT

107 ITR 938 · 1977 · Supreme Court

477

citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.

208 ITR 465 · 1994 · High Court

427

citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT

172 ITR 250 · 1988 · Supreme Court

340

citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Ramesh Corporation Automobiles, Ahmedabad vs. The ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal is allowed for statistical purposes

ITA 4/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad11 Apr 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri S. N. Divatia & Shri SamirFor Respondent: Smt. Mamta Singh, Sr.DR

Section 115BSection 143(3)Section 148Section 250Section 271ASection 69A

view that the explanation was improbable and inconsistent with human conduct. Consequently, he treated the entire deposit of Rs. 13,03,738/- as unexplained money under Section 69A of the Act and taxed the same under Section 115BBE. Penalty proceedings under Section 271AAC were also initiated separately. 7. The assessee

Income Tax Officer, Ward-3(3)(1), Ahmedabad vs. Arvindbhai R Nanavati HUF, Ahmedabad

In the result, appeal filed by the Revenue is dismissed

ITA 1717/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad11 Apr 2025AY 2017-18

Bench: DR. BRR KUMAR (Vice President), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri A. K. Khandelwal, ARFor Respondent: Shri B. P. Srivastav, Sr.DR

Section 133(6)Section 139(1)Section 144Section 148Section 69A

addition of Rs. 1,12,13,500/- made by the AO on account of unsecured loan received from various lenders treating it as unexplained money u/s 69A of the IT Act. (b) The Ld. CIT(A) has erred in law and on facts in not appreciating the facts that ... which it is mentioned as 'Accordingly the amount of Rs. 1,12,13,500/- is added to the income of the assessee as unexplained money u/s.69A of the Act. However, at any later stage / appellate proceedings, if the assessee produces any books of accounts and claimed that the amount

Shahanavajkhan Daudkhan Pathan, Mumbai vs. Income Tax Officer Ward 34(3)(1), Mumbai

ITA 3675/MUM/2024[2012-13]Status: DisposedITAT Mumbai11 Apr 2025AY 2012-13

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Shahanavajkhan Ito Ward 34(3)(1) Daudkhan Pathan Vashi Railway Sector 1, House No. 1 Vs. Station Building G-1 Lane, Cheeta Vashi, Navi Camp, Trombay Mumbai-400 703. Mumbai-400 088. Pan : Arkpp6986H Appellant Respondent

For Appellant: Shri Pravin SalunkheFor Respondent: Shri Rohit Tapadiya, CA

Section 69Section 69A

party order by making various addition which inter alia included addition of Rs. 14,40,443/- u/s 69 of the IT Act, being unexplained Money. 2. Upon appeal to CIT-A, I have filed various details including bank statement and CIT-A deleted other additions as well as restricted

Ritu Singhal, Dehradun vs. DCIT/ACIT Central Circle, Dehradun

In the result, the appeal of the assessee is allowed

ITA 224/DDN/2024[2019-20]Status: DisposedITAT Dehradun09 Apr 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Ritu Singhal, Vs. Dcit/ Acit, 34F, Narndra Vihar, Central Circle, Kaulagarh Road, Dehradun Uttarakhand (Appellant) (Respondent) Pan:Bayps8429Q Assessee By : Shri Harshit Gupta, Ca Revenue By: Shri S. K. Chaterjee, Cit Dr Date Of Hearing 19/03/2025 Date Of Pronouncement 09/04/2025

For Appellant: Shri Harshit Gupta, CAFor Respondent: Shri S. K. Chaterjee, CIT DR

Section 115BSection 139(1)Section 147Section 40A(3)Section 69A

passbooks and ATMs of the some employees found at the time of search, the ld AO made addition of Rs. 14,63,000/- as unexplained money u/s 69A of the Act read with Section 115BBE of the Act. Further, the ld AO made an addition

Ramender Singh, Dehradun vs. Income Tax Officer, Dehradun

In the result, appeal of the assessee is allowed

ITA 17/DDN/2024[2017-18]Status: DisposedITAT Dehradun09 Apr 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Ramender Singh, Vs. Ito, 58A, Khurbura Mohalla, Dehradun Uttarakhand (Appellant) (Respondent) Pan:Cbnps9195N Assessee By : Shri K. K. Juneja, Adv Revenue By: Shri S. K. Chaterjee, Cit Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 09/04/2025

For Appellant: Shri K. K. Juneja, AdvFor Respondent: Shri S. K. Chaterjee, CIT DR

Section 115BSection 143(3)Section 69A

assessee in this regard, merely because cash was deposited during demonetization period, a sum of Rs. 7,50,000/- was treated as unexplained money in the hands of the assessee u/s 69A read with Section 115BBE of the Act by the ld AO, which stood upheld by the ld NFAC ... preceding year explains the source of cash deposits made in the bank account. Hence, there is no question of treating the cash deposit as unexplained money u/s 69A of the Act. Accordingly, the grounds raised by the assessee are allowed. 5. In the result, appeal of the assessee is allowed

Hena Sahil, Dehradun vs. Commissioner of Income Tax (Appeals), Delhi

In the result, the appeal of the assessee is allowed

ITA 138/DDN/2024[2017-18]Status: DisposedITAT Dehradun09 Apr 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Hena Sahil, Vs. Acit, 13-A, Subash Road, Circle-1(1)(1), Dehradun, Uttarakhand Dehradun Pan: Aalpf6610J Assessee By : Shri Tarandeep Singh, Adv Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 19/03/2025 Date Of Pronouncement 09/04/2025

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri A. S. Rana, Sr. DR

Section 115BSection 143(3)Section 69A

whether the ld CIT(A) was justified in confirming the addition made on account of cash deposits during the demonetization period as unexplained money u/s 69A read with Section 115BBE of the Act in the facts and circumstances of the instant case. Hena Sahil 3. We have heard the rival ... bank accounts. The ld AO was not satisfied with the reply and proceeded to treat the cash deposits made in the bank account as unexplained money u/s 69A read with Section 115BBE of the Act. 4. Before the ld CIT(A), the assessee explained that the father of the assessee

Shashikala Bhimacharya Malagi, Gokak, Karnataka vs. ITO, Ward-1, Gokak, Karnatka

The appeal is partly allowed in aforestated terms

ITA 180/PAN/2023[2017-18]Status: DisposedITAT Panaji09 Apr 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 180/Pan/2023 Assessment Year : 2017-18 Shashikala Bhimacharya Malagi 0, Soubhagya, Kalyan Housing Colony, Gokak, Belgaum-591307 Pan : Bdypm3708B . . . . . . .Appellant V/S Income Tax Officer, Ward-1, Gokak. . . . . . . . Respondent Appearances Assessee By : Mr Himanshu Gandhi [‘Ld. Ar’] Revenue By : Mr Narendra Reddy [‘Ld. Dr’] Date Of Conclusive Hearing : 08/04/2025 Date Of Pronouncement : 09/04/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order No. 1055706480(1) Dt. 04/09/2023 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 20/12/2019 Passed U/S 143(3) Of The Act Anent To Assessment Year 2017-18 [‘Ay’ Hereinafter].

For Appellant: Mr Himanshu Gandhi [‘Ld. AR’]For Respondent: Mr Narendra Reddy [‘Ld. DR’]

Section 115BSection 139(1)Section 143(2)Section 143(3)Section 250Section 69A

Bank accounts respectively, unsatisfactory the Ld. AO culminated the proceeding by bringing to tax entire deposits u/s 69A r.w.s. 115BBE of the Act as unexplained money & framed consequential assessment u/s 143(3) of the Act. Aggrieved by the additions the assessee instituted an appeal thereagainst before Ld. NFAC, which also ... from cash received from family members for her upkeepment, did fail to inspire any confidence to the Ld. AO, hence treated the same as unexplained money u/s 69A and brought to tax u/s 115BBE of the Act. When matter travelled up in appeal, the Ld. NFAC countenanced the addition echoing

Payal Verma, Bhilai, Durg vs. Income Tax Officer, Ward-1(3), Bhilai, Durg

In the result, appeal of the assessee is allowed

ITA 341/RPR/2024[2017-18]Status: DisposedITAT Raipur09 Apr 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.341/Rpr/2024 "नधा"रण वष" /Assessment Year : 2017-18 Payel Verma Prop. M/S. Jai Vriddhi Traders, Ananj Mandi Line, Behind Nehru Bhawan, Supela Bhilai-490 023 Pan: Aovpv3159G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(3), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Mrs. Payel Verma, AssesseeFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 115BSection 143(3)Section 145(3)Section 69A

made the addition of the cash deposits in demonetized currency of Rs.17,61,000/- u/s. 69A of the Act as unexplained money in the hands of the assessee. 3. The Ld. CIT(Appeals)/NFAC had summarily confirmed the findings of the A.O. 4. I have carefully considered the submission ... have been fulfilled by the assessee, there cannot be any addition u/s.69A of the Act treating the cash deposits in the bank account as unexplained money of the assessee. In view thereof, I set-aside the order of the Ld. CIT(Appeals)/NFAC and direct the A.O to delete

Trichur Heart Hospital Limited, Thrissur vs. DCIT, Circle 1(1) & Tps, Thrissur

In the result, the appeal filed by the assessee is partly allowed

ITA 915/COCH/2024[2017-18]Status: DisposedITAT Cochin09 Apr 2025AY 2017-18

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Harikrishnanunny, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)

whether the AO was justified in making addition of cash deposits made in SBN during demonetisation period of Rs. 45,74,000/- as unexplained money. During the course of assessment proceedings as well as before the CIT(A), it is asserted that the appellant made the above cash deposit

Incometax Officer, Non Corporate Ward 2(4), Kochi vs. Kochin Co Operative Society Ltd, Mattancherry

In the result, the appeals filed by the Revenue stand partly allowed

ITA 663/COCH/2023[2013-14]Status: DisposedITAT Cochin09 Apr 2025AY 2013-14

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Sanjit Kumar Das, CIT-DRFor Respondent: Ms. Niveditha K. Kammath, Advocate

Section 139(1)Section 144Section 148Section 69ASection 80P

compelled to make best judgement assessment invoking provisions of section 144 of the Act. While doing so, the AO treated the cash deposit as unexplained money of the assessee, while denying claim for deduction u/s. 80P of the Act. 4. Being aggrieved, appeal was filed before

Income Tax Officer, I S Press Road, Kochi vs. Kochin Co Operative Society Ltd, Mattancherry

In the result, the appeals filed by the Revenue stand partly allowed

ITA 644/COCH/2023[2014-15]Status: DisposedITAT Cochin09 Apr 2025AY 2014-15

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Sanjit Kumar Das, CIT-DRFor Respondent: Ms. Niveditha K. Kammath, Advocate

Section 139(1)Section 144Section 148Section 69ASection 80P

Prakash Chand Varindani, Jaipur vs. ACIT Certal Cirlce-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1146/JPR/2024[2017-18]Status: DisposedITAT Jaipur09 Apr 2025AY 2017-18

Bench: Him. 2

For Appellant: Sh. Abhishek Soni, CAFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 144Section 40A(3)Section 68

credit entries are made in the books of account of the assessce or not. Further, without prejudice, alternatively, such unexplained cash is taxable as unexplained money u/s 69A of the Act and it is held accordingly. Furthermore, cash book (rokad bahi) and ledger accounts maintained by the appellant were impounded

Masengji Kalaji Solanki, Banaskantha vs. The ITO, Ward-3, Palanpur

In the result, the appeal of the assessee is allowed

ITA 1939/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad09 Apr 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Jimi Patel, ARFor Respondent: Shri Kavan Limbasiya, Sr DR

Section 143(3)Section 148Section 156Section 250Section 69A

explanations, leaving the source of the cash deposit unexplained, the cash deposit of Rs. 59,01,400/- was treated by the Assessing Officer as unexplained money u/s 69A of the Act and was added to the total income of the assessee. 4. Aggrieved by the order of the Assessing Officer

Chidrawar Narendra Hanmannlu HUF, Nanded vs. ITO Ward-1, Nanded

In the result, all the three appeals filed by assessee are allowed for statistical purposes

ITA 2672/PUN/2024[2018-19]Status: HeardITAT Pune09 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Pawan MundadaFor Respondent: Shri Ramnath P Murkunde

Section 142(1)Section 144Section 148Section 271ASection 272A(1)(d)Section 69A

No.2672/PUN/2024 relates to the order of the Ld. CIT(A) / NFAC sustaining the addition of Rs.72,72,500/- made by the Assessing Officer as unexplained money u/s 69A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’), ITA No.2669/PUN/2024 relates to the ex- parte order ... assessment u/s 144 of the Act determining the total income of the assessee at Rs.72,72,500/- by making addition of the same as unexplained money u/s 69A of the Act. 3. Since the assessee did not make any submission before the Ld. CIT(A) / NFAC despite three opportunities granted

Chidrawar Narendra Hanmanlu HUF, Nanded vs. ITO Ward-1, Nanded

In the result, all the three appeals filed by assessee are allowed for statistical purposes

ITA 2671/PUN/2024[2018-19]Status: HeardITAT Pune09 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Pawan MundadaFor Respondent: Shri Ramnath P Murkunde

Section 142(1)Section 144Section 148Section 271ASection 272A(1)(d)Section 69A

Chidrawar Narendra Hanmanlu HUF, Nanded vs. ITO Ward-1, Nanded

In the result, all the three appeals filed by assessee are allowed for statistical purposes

ITA 2669/PUN/2024[2018-19]Status: HeardITAT Pune09 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Pawan MundadaFor Respondent: Shri Ramnath P Murkunde

Section 142(1)Section 144Section 148Section 271ASection 272A(1)(d)Section 69A

Karamavir Nagari Sahakari Patsansth Maryadit Ashta, Sangli vs. C.I.T (A), Sangli

In the result, both the appeals filed by the assessee are allowed for statistical purposes and both the SAs filed by the assessee are dismissed

ITA 2655/PUN/2024[2018-19]Status: HeardITAT Pune09 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Umesh Kumar Madhukar MaliFor Respondent: Shri Ramnath P Murkunde

Section 144Section 147Section 148Section 148ASection 69ASection 80P

Assessing Officer in the instant case made addition of Rs.2,17,86,112/- u/s 69A of the Act u/s 69A of the Act as unexplained money on the ground that out of total deposit of Rs.3,23,71,885/- the assessee could explain the source of deposit only

Karmavir Nagari Sahakari Patsanstha Maryadit Ashta, Sangli vs. CIT (A), Sangli

In the result, both the appeals filed by the assessee are allowed for statistical purposes and both the SAs filed by the assessee are dismissed

ITA 2591/PUN/2024[2019-20]Status: HeardITAT Pune09 Apr 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Umesh Kumar Madhukar MaliFor Respondent: Shri Ramnath P Murkunde

Section 144Section 147Section 148Section 148ASection 69ASection 80P

Tatyasaheb Narayan Lagad, Pune vs. ITO Ward 6(2), Pune

In the result, the appeal filed by the assessee is partly allowed

ITA 1587/PUN/2024[2017-18]Status: DisposedITAT Pune09 Apr 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Tatyasaheb Narayan Lagad Ito, Ward 6(2), Pune B-504, Crossover Country, Sinhagad Vs. Road, Wadgaon Khurd, Pune – 411041 Pan: Acypl2714L (Appellant) (Respondent) Assessee By : Shri Suhas Bora Department By : Shri Vishwas Mundhe Date Of Hearing : 20-02-2025 Date Of Pronouncement : 09-04-2025 O R D E R

For Appellant: Shri Suhas BoraFor Respondent: Shri Vishwas Mundhe

Section 143(2)Section 69A

completed the assessment by assessing the total income at Rs. 29,48,520/- by adding an amount of Rs. 21,40,780/-being unexplained money u/s 69A of the Income Tax Act, 1961 to the total Income of the appellant. Being aggrieved by the same the appellant has preferred instant ... account ie out of the opening cash balance. As the matter pertains to Section 69A the provisions of Section 69A are reproduced: Section 69A - Unexplained Money "Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such

Arumugam Dhandapani, Tiruvannamalai vs. ITO, Ward-1, Tiruvannamalai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2964/CHNY/2024[2017-18]Status: DisposedITAT Chennai09 Apr 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2964/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Arumugam Dhandapani, Vs. The Income Tax Officer, No. 25, Velananthal Main Road, Ward 1, Velananthal, Rajapalayam Post, Tiruvannamalai. Tiruvannamalai 606 755. [Pan:Bvwpd5386C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Anandd Babunath, Ca ""थ" की ओर से/Respondent By : Shri N. Madan Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 03.04.2025 घोषणा की तारीख /Date Of Pronouncement : 09.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Additions Made By The Assessing Officer On Account Of Treating Cash Deposits During Demonetization Period As 2

For Appellant: Shri Anandd Babunath, CAFor Respondent: Shri N. Madan Kumar, JCIT

Section 133(6)Section 142(1)Section 144Section 44ASection 69A

explanation offered to establish the source and nature of the cash deposits of ₹.11,52,260/-, the Assessing Officer treated the same as unexplained money of the assessee under section 69A of the Act and brought to tax. On appeal, the ld. CIT(A) confirmed the addition made